Will Immigration Professionals Sign Affirmation --
Or Will They Conspire to Hide Allen Kaye's Crimes?
UNITED STATES DISTRICT COURT
DISTRICT OF NEW YORK
Cheryl D. Uzamere
Civil Court Docket No:
- against -
Kaye, P.C.; Uzamere and Associates,
PLLC; Fried, Frank, Harris, Shriver &
LLP; Allen E. Kaye Esq.; Eugene O. Uzamere,
Esq.; Robert E. Juceam, Esq.; Jack Gladstein,
Esq.; Eugenia Cowles,
Esq.; Rachel McCarthy,
Esq.; Andrew Cuomo, Esq.; Honorable
Bloomberg; Honorable A. Gail Prudenti, Justice
of the Appellate Court 2nd Judicial Department;
Honorable Abraham Gerges, Justice of the
Supreme Court, Kings County;
S. Sunshine, Justice of Supreme Court Kings County;
James Edward Pelzer, Clerk of Appellate Court
Judicial Department; Joseph Visceglia, Municipal
Clerk; Bernard J.
Rostansky, Notary Public; State
of New York; City of New York and New York
STATE OF NEW YORK )
COUNTY OF KINGS ) ss:
I, Allen E. Kaye, an attorney duly admitted to practice law in the courts
of the State of New York, hereby affirm the following under penalties of perjury:
1) I am the owner and principal attorney of the law
firm Allen E. Kaye, P.C., located at 233 Broadway, New York, New York, 10006. I am fully familiar with the facts and circumstances
contained in the subject Affirmation. My knowledge and information is based on the records maintained by my office, communications
with the individual photographed in Exhibit A and with other individuals with whom I discussed issues as they
pertain to this case.
2) I recognize that the Plaintiff in the above-entitled
action, in an attempt to apprise American citizens and to protect them from the dangers associated with corrupt immigration
attorneys and immigrants who engage in green card marriage scams and other forms of immigration fraud, has uploaded the
subject Affirmation to her website, http://www.thecrimesofsenatoruzamere.com.
3) I affirm that the statements herein presented are true and correct, and that I am wholly and solely responsible
for any negative consequence to my career, my professional reputation and Plaintiff's perception of green card marriages
as outlined on Plaintiff's web page http://www.thecrimesofsenatoruzamere.com/end_green_card_marriage_sponsorship.html that include, but are not limited to: investigations conducted against me by governmental agencies, arrest,
imprisonment, disbarment, suspension, censure, subpoenas, lawsuits, federal or state court's decision against me regarding
any acts of fraud, omissions or other acts of impropriety, and any other damages arising from my intentional misrepresentation
of the facts as contained in the subject Affirmation.
4) That the individual photographed in Exhibit A is my client.
5) That before November 30, 1979, neither I nor anyone
in my employ was retained to provide legal services on behalf of the individual photographed in Exhibit A, nor did I collect
monies or provide pro bono legal services on behalf of the individual photographed in Exhibit A.
6) That neither the United States Citizenship and Immigration
Service nor any other federal agency is in possession of records that reflect that I provided legal services on behalf of
the individual photographed in Exhibit A before November 30, 1979.
7) That before November 30, 1979, neither I, nor anyone in my employ knew the individual photographed in
Exhibit A by his real name or any other name.
8) That on or around November
30, 1979, the individual photographed in Exhibit A came into my office for the first time and met with “an attorney
associated with Mr. Kaye...in connection with a petition for an immediate relative” as outlined in correspondence prepared
by Rachel McCarthy, Bar Counsel of the USCIS (see Exhibit B).
9) That the individual photographed in Exhibit A presented to the “attorney associated with Mr. Kaye”
a copy of his marriage license or other identification as proof of marriage to Cheryl D. Uzamere, formerly known as Cheryl
D. Duncan (see Exhibit C).
That the individual to whom USCIS' statement “an attorney associated with Mr. Kaye's firm” refers is Harvey
Shapiro, as indicated by Mr. Shapiro's signature above my law firm's name on the I-130 that was signed by the Plaintiff
(see Exhibit D pages 1-4).
That on or around November 30, 1979, the individual photographed in Exhibit A presented marriage documentation containing
the fictitious name “Godwin E. Uzamere.”
12) That on or around November 30, 1979, Plaintiff signed her maiden name on the aforesaid immigration form
without knowing that my associate Harvey Shapiro had accepted her husband's fictitious name “Godwin E. Uzamere”
as true and correct.
That on or around November 30, 1979, that my associate Harvey Shapiro did not verify the identity of the individual photographed
in Exhibit A by viewing the aforesaid individual's passport, driver's license, college identification, birth papers,
baptismal certificate or other official and accurate documentation as required by New York State and U.S. immigration laws,
as outlined in Exhibit E (page 2 of 2); and that Harvey Shapiro failed to properly verify the identity of the individual photographed
in Exhibit A; and that having placed supervisory responsibilities for the processing of the aforesaid individual's request
for permanent residence with Harvey Shapiro, I had no further involvement with the individual photographed in Exhibit A with
regard to his petition for immediate relative sponsorship through the Plaintiff.
14) That with regard to having placed supervisory responsibilities for the processing of the aforesaid individual's
request for permanent residence with Harvey Shapiro, existing laws of agency or other commercial laws holding a company's
principal is liable for the acts of his/her agents, necessarily requiring me to ensure that my associate Harvey Shapiro's
processing of the aforesaid individual's request for permanent residence was true and correct, did not apply to me at
the time that Harvey Shapiro submitted the falsified I-130 form to be notarized.
15) That I recognize that as a direct result of Harvey Shapiro's processing the request of the individual
photographed in Exhibit A with the fraudulent information “Godwin E. Uzamere, date of birth, June 1, 1955”, and
as a direct of Harvey Shapiro failure to check the aforesaid individual's passport, driver's license, college identification,
birth papers, baptismal certificate or other official and accurate documentation as required by New York State and U.S. immigration
laws, and outlined in Exhibit E (page 2 of 2), Plaintiff was unable to obtain child and spousal support for the life of the
16) That I affirm
that the names “Ehigie Edobor Uzamere” and “Godwin E. Uzamere” belong to Senator Ehigie Edobor Uzamere;
and that said individual is the Plaintiff's husband.
17) That the affirmation of Eugene O. Uzamere, Esq., regarding the identity of the individual photographed
in Exhibit A is fraudulent, inaccurate and without merit (see Exhibit F (pages 1, 2).
That as the owner and principal of the law firm Allen E. Kaye, P.C., I have never engaged in any form of willful blindness,
such as intentionally placing supervisory responsibilities on associates, subordinates or other agents in my employ to process
fraudulent immigration request so that I can feign lack of knowledge.
I submit this Affirmation willingly and with no explicit, implicit or coerced understanding that if I place blame on Harvey
Shapiro or on an as yet unknown agent, the Plaintiff will end her complaints against me in exchange for my influencing the
judge in Plaintiff's divorce action to grant her motion for default judgment and money judgment against her husband.
20) That I submit this Affirmation knowing
that the Plaintiff believes me to be wholly and solely liable for the acts of my associate, Harvey Shapiro based on her understanding
of the laws of agency; that Plaintiff cannot legally or logically accede to any explicit, implicit, coerced or other “understood”
request allowing me to place blame on former agency Harvey Shapiro insofar as Plaintiff would consider such an act to be dishonest;
and that such an act would leave Plaintiff open to lawsuit by me based on defamation of character.
21) That I am willing to go forward to hold former associate Harvey
Shapiro liable for submitting the I-130 signed by the Plaintiff and to assist in Harvey Shapiro's prosecution.
22) I understand that if I refuse to
sign this Affirmation as presented by the Plaintiff that Plaintiff will use my refusal as proof that I am guilty of the allegations
for which I stand accused.
WHEREFORE, as Harvey Shapiro is responsible for the processing
of the aforesaid I-130 form in a manner that is inconsistent with New York State and U.S. laws that require the production
of verifiable identification, and that Harvey Shapiro's processing of the fraudulent I-130 form on behalf of the Plaintiff's
husband is the proximate cause for the loss of income to Plaintiff and her children, I respectfully submit that this court
direct its investigation to Harvey Shapiro for litigation, prosecution and for other and further actions as to this Court
seem just and proper.
Dated: Brooklyn, NY
January 10, 2009
Allen E. Kaye, Esq.
Allen E. Kaye, P.C.
233 Broadway, New York, NY 10006